PRESENTATION

TOPIC: COMPARATIVE CONSTITUTIONAL ANALYSIS

OF PAKISTAN & UK CONSTITUTION

Submitted to the course instructor.

SIR ALI ABBAS ABIDI
(COMPARATIVE CONSTITUTION LAW)
LM-III--(Sec.A)
(FALL 2023)
by
MEHTAB GUL- Roll No.LM-0342

Shaheed Zulfiqar Ali Bhutto University of

Law (SZABUL)
Karachi-Pakistan
DECEMBER 2023

1. BACKGROUND OF CONSTITUTION
U. K constitution is a developed constitution. It has attained it’s present form 14 hundred years
of development and is still under development as it is evolutionary and organic in nature. Its
growth started since Magna Carta in 1215. All-important constitutional documents, statutes
conventions and judicial decisions are part of U.K constitution.
In contrast to that 4 constitutions were introduced in Pakistan (1956, 1962, 1972 and 1973)
constitution. But 1956 constitution was abrogated on 7 Oct 1958 by president iskandar Mirza and
1962 constitution was abrogated by president Yahya khan on 25th march 1969. 1972 constitution
was temporary and 1973 constitution is still present.

2. SOURCES OF CONSTITUTIONS

U.K constitution is un- codified and partially written constitution and is not contained in single
document therefore it is based on different sources such as

2.1 CONSTITUTIONAL LAND MARK: Some parts of the English constitution is

written in the form of constitutional landmark and statutes the great constitutional landmark are
mentioned in below but these laws covers only a small part of the constitution.
2.2 MEGNACARTA 1215: The Magna Carta (great charter) was signed by King John in
1215. It was an agreement between king and public (Barron’s) through which the King
recognized the fundamental rights of people. It was also agreed upon that the King must govern
according to law and not according to his will.
2.3 PETATION OF RIGHTS 1628: The Petition of Rights was signed in reign of King
Charles-I in 1628. Through this Petition it was decided that the King would not impose any tax
without the consent of the parliament.
2.4 REFORM ACT OF 1832: The various reform Acts granted to the public the right of
vote and representation in the parliament.
2.5 PARLIAMENT ACT OF 1911: The House of Commons is more supreme than the
House of Lords .The Parliament Act deals with the powers of the House of Lords.
2.6 BILL OF RIGHTS 1789: The Bill of Rights of 1789 shifted the balance of power
from the King to the Parliament. .
2.7 ACTS OF SETTLEMENT 1701: The Act of Settlement provided that the King
must be of Protestant faith.
2.8 STATUTS OF PARLIAMENT: These are the laws made by the parliaments over
many centuries some of them relate to the methods of elections, duties of officials etc. Such laws
are also of constitutional significance
⚫ HABEAUS CARPOUS ACT 1671: The Act of Habeas Corpus stipulated that a person who
is imprisoned without legal justification must be presented to a court of law.
⚫ JUDICATURE ACT 1873
⚫ HUMAN RIGHTS 1998: This Act incorporates most of the rights and freedoms guaranteed
under the European Convention on Human Rights into domestic law.
 2.9 JUDICIAL DECISION: Another source of the British Constitution are judicial
decisions of the British higher courts.
2.10 COMMON LAW: A common law is main made law which has not been made by
any legislature but rests on customs and is enforced by the courts. A substantial part of U.K
constitution is based on common law.
Many basic rights of the people e.g. jury trial, freedom of speech and assembly are based on
Common Law.
2.11 OPNION OF JURIS AND TREATIES: Opinion of jurists and Treaties are also an
important source of U.K constitution.
2.12 CONVENTIONS: Another source of British constitution is large number of
conventions which are customs, usages practices . Conventions are not a law therefore cannot be
enforced by the courts. The substantial portion of UK Constitution is based on convention. . The
Courts do not enforce conventions but however, these rules are recognized by the constitution.

Examples:
1-The queen cannot go against the advice of the cabinet
2-The PM must sit in the House of Commons British Constitution

THE SOURCES OF CONSTITUTION OF PAKISTAN ARE AS FOLLOWS:

1-INDIAN GOVERNMENT ACT 1935: The Constitution of Pakistan draws some of its
provisions from the Government of India Act, 1935, which was the governing document for
British India.
2-OBJECTIVE RESOLUTION: The Objective Resolution was adopted by the Constituent
Assembly of Pakistan in 1949 and later included in the preamble of the Constitution. It provides
the guiding principles for the constitution-making process and asserts the principles of
democracy, equality, and social justice.
3-ISLAMIC PRINCIPLES: As an Islamic Republic, the Constitution of Pakistan incorporates
principles of Islam. The constitution includes provisions derived from Islamic law (Sharia) and
aims to ensure that all laws are in conformity with Islamic teachings.
3. NATURE/SAILENT FEATURES OF THE CONSTITUTION

3.1 WRITTEN AND UNWRITTEN CONSTITUTION:

The constitution of Pakistan is a written constitution and a codified and enacted by parliament
and contained in 1 single document. It contains 12 parts, 280 articles, 7 schedules and 25
amendments.
In contrast to that U.K constitution considered as unwritten, un-codified, not contained in one
single document and not passed by parliament. But can be found in various sources such as
statutes, conventions, judicial decisions /common law. But many of its sources such as statutes,
judicial decisions and charter are in written form it means that UK constitution is not wholly
unwritten constitution it is partly written and partly unwritten.

3.2 SOVEREIGNTY OF PARLIAMNET AND CONSTITUTIONAL SUPREMAC:

British parliament is sovereign. There is no other institution including judiciary to work as a
check on supremacy of parliament. “It is said that the parliament of the Britain can make or
unmake anything, law and constitution, even can change the nature of the constitution except
making a Man a Woman and a woman a Man’’. There is no any difference between ordinary law
passed by parliament in U.K and its constitution .
In contrast to that Pakistan constitution of 1973 is supreme law of the land and sovereignty over
the entire universe belongs to Allah almighty alone as mentioned in the preamble. The state
derives its existence from the constitution and powers of the central and state governments are
delegated by the constitution. No organ of the state can legally exercise single power which is
inconsistent with the articles of the constitution.
The parliament in Pakistan is subordinate lawmaking body, not absolute sovereign as it cannot
change the very nature of the constitution and if any law passed by it goes beyond the
constitution, it can be declared null and void by the Supreme Court establishing the principle of
supremacy of the constitutions.

3.3 FLEXIBILTY, RIGIDITY AND AMENDMENT:

The method of amendment is the criteria to determine flexibility or rigidity of the constitution.
British constitution is the most flexible constitution of the world as it can be amended by an
ordinary lawmaking procedure by the parliament. A simple majority of both Houses is required
to amend it. Every new act of British parliament and every new judicial decision of British courts
amend the British constitution.

The constitution of Pakistan 1973 is moderately rigid in nature. It is not so flexible like British
constitution and not so rigid like USA constitution. There is specific heavy procedure provided
for amendment in constitution. Each House has to pass the bill with 2/3 rd majority of the total
membership of that house then presented before president for assent. If amendment relates to the
limits of the province, then it must be passed by the majority of the legislative assembly of the
province concerned.
3.4. SEPARATION OF POWERS
Constitution of 1973 in Pakistan does not provide true separation of powers between 3 different
organs of government. In fact, constitution hardly provides any balance of powers between these
organs of government.

Reasons
3.4.1. President assent to bills and ordinance power
President gives assent to each bill or can return the same passed by both houses under article 75.
President even can promulgate ordinances under article 89. But article 90 of 1973 constitution
says that subject to the constitution the executive authority of the federation shall be exercised in
the name of the president by the federal government it means that president is also a part of
executive.
3.4.2. Delegated legislation
Executive /government department’s by exercising power of delegated legislation by parliament
makes their own rules, by laws.

3.4.3. President judicial powers.

President can appoint judges of Supreme Court and High court with consultation of chief justice
of Supreme Court under article 177.
3.4.4. P.M and Cabinet from Nation Assembly
Prime Minister is elected from National Assembly. Cabinet members are also mostly taken from
National assembly and 25 percent from senate. Cabinet and P.M both are members of parliament
and sit together in National assembly and pass the legislation.
3.4.5. Interpretation of statutes
Judiciary in Pakistan also legislate to some extent through interpretation of statutes which is
extended legislation as it’s only after judicial interpretation it is known that whether the intention
of those who framed the law have actually been carried into effect or not.
In contrast to that there is also a separation powers concept exists in the U.K like in Pakistan but
distinct and complete separation powers like in U.S.A does not exists due to un-codified and
largely unwritten constitution.
Examples of fusion of power in U.K
1.. Before 2009 the legislative branch had both legislative and judicial powers, with the highest
appeal court being an appellate committee in the House of Lords (The Law Lords). But after
reforms at 2005 judicial authority was taken from House of lords and new independent supreme
court was established which is now highest and final court of appeal for all cases in U.K.
2. The executive branch also has legislative functions in the sense that they sit in the House of
Commons and pass legislation just like in Pakistan

3. Judiciary has the ability to make law in the sense that they contribute to the common law.
4. The Lord Chancellor before 2005 was seen best example of lack of separation of powers in
U.K.

• He had the power to sit as a member and contribute to decisions made in cabinet
meetings
 • He was the head of the judiciary and senior judge of the House of Lords in its judicial
capacity.
• Speaker in the House of Lords.

• But constitutional reforms act 2005 changed the role of Lord Chancellor.
• His judicial functions removed and no longer sit in the House of Lords as speaker, thus
signifying the representation of separation of powers
• Now he can be only a member of the cabinet and the job of presiding over the house
lord’s proceedings transferred from the Lord Chancellor to a newly created role the Lord
speaker.
• A judicial appointments commission was created and took over the Lord Chancellor
power to appoint senior judges for English and wales courts.
• Constitutional reforms act 2005 played a role in more formal separation of powers
principle in U.K.
3.5. FEDERAL AND UNITARY CONSTITUTION
British constitution provides unitary form of government and all powers are concentrated in the
hands of central government. Local governments are the creation of and derive their powers from
the central government and as such are subordinate to the center all respects. They are agents of
the central government.
However, Pakistan constitution 1973 is federal constitution which provides federal form of
government. Powers are constitutional divided between central government and units. In this
system 2 types of government exists, regional and national. In the federation units are
independent of the center in their own spheres.

3.6 JUDICIAL REVIEW

Pakistan constitution 1973 article 184(3) confers a judicial review power on the Supreme Court
and its article 199 confers the same upon the High court of the provinces. Supreme Court is the
guardian of the constitution it can declare null and void any law passed by legislature or the acts
of the executive if it contravenes the provisions of the constitution.

In contrast to that there is no broader concept of judicial review in U. K because of the

parliamentary supremacy. The courts can not directly strike down any primary legislation for
being unconstitutional but they do ensure that those exercising public functions are acting within
the limits of their powers.
3.7 EVOLUTIONARY AND NON-EVOLUTIONARY CONSTITUTION

British constitution is an evolutionary constitution. It was not framed by any constituent

assembly. It has not been made rather it has grown with space of time to cope with new political
realities and situations. It has grown by constitutional landmarks, statutes, precedents, common
laws, judicial decisions and conventions. According to Dr. Jenning English constitution is the
child of evolution.
In contrast to that Pakistan constitutions is non- evolutionary in nature. Pakistan first and 2nd
constitutions were abrogated on 7th Oct 1958 and 25th march 1969. After 1973 constitution
coming into force first 2 constitutions is not applicable and now constitution can be amended
only through heavy procedure.
3.8 PERMANANET CONSTITUTION

Constitution of Pakistan 1973 is permanent constitution Article 6 guarantees its permanency. In

contrast to that I.K constitution is not permanent one as it is unwritten and un-codified and can
be enacted, repealed and amended by parliament using its ordinary legislative procedures.
3.9 UNREALITY
British constitution is unreal constitution. It is one thing in theory but different in actual practice.
In theory all powers are granted to the king but in practice all powers are enjoyed by the House
of Commons or we can say by the P.M. The real powers are enjoyed by the people irrespective
of the fact that constitution grants them to the Monarch.
But there is no any unreality in Pakistan constitution 1973 as because all powers are specifically
distributed to each organ of government and no one can take powers of others.

3.10 FEDERAL AND UNITARY CONSTITUTION

British constitution provides unitary form of government and all powers are concentrated in the
hands of central government. Local governments are the creation of and derive their powers from
the central government and as such are subordinate to the center in all respects. They are agents
of the central government.

However, Pakistan constitution 1973 is federal constitution which provides federal form of
government. Powers are constitutionally divided between central government and its units. In
this system 2 types of government exists, regional and national. In the federation units are
independent of the center in their own spheres.
3.11 STATE RELIGION
U. K does not have any official state religion. The Church of England is, the state church but the
Monarch is the head of Church of England. Pakistan is an Islamic republic .Islam is the official
state religion of Pakistan under article 2.
3.12 MULTI-PARTY & 2 PARTY SYSTEM
There is multi-party system BUT In UK there is 2 party systems.
1. Labor party
2. Conservative party.
3.13 CONSTITUTIONAL MONARCHY
In U.K there is constitutional Monarchy with ceremonial and non-executive and non-elected
monarch with just a ceremonial role. Where a separate head of government (P.M) leads the
executive Earlier monarch in British constitution was more powerful but with rise of parliament
and responsible government monarch now plays only ceremonial role.
Pakistan was also a constitutional monarchy and had a dominion status from 1947 to
1956.Governor generals were the representatives of British monarch in Pakistan. Monarchy in
Pakistan abolished on 23 March 1956 with adoption of its 1st constitution, when Pakistan
became a republic within the common wealth with a president as its head of state.
3.14 FORM OF GOVERNMENT
In U. K there is a constitutional monarchy with unitary and parliamentary form of government. It
means that the monarch is the head of state but does not have any real direct executive power.
Monarch has just ceremonial role. All the executive powers is exercised by the Prime Minister
and his cabinet. P.M is the head of the political party that wins the most seats in the House of
Commons.
In contrast to that there is no constitutional Monarchy in Pakistan under 1973 constitution.
Pakistan is a federal parliamentary republic, which means that the president is the head of the
head of state and the prime minister is the head of the government. Prime minister is the leader
of the political party that wins the most seats in the National assembly.
3.15 LAW-MAKING PROCEDURE
In U.K ordinary bill can be originated in any House except money bill which can only originate
in HOC. If bill is passed by both Houses, then it goes for royal assent to Monarch. HOL can
only delay an ordinary bill for 1 year only. After elapse of 1 year bill becomes a law without
HOL approval. If bill originate in HOL and is passed by it then if HOC rejects it, the bill will die.
Almost similar procedure available in Pakistan for law making. Bill can be originated in any
House except money bill which can only be originated in NA. If bill is passed by both Houses
with simple majority, it is then sent to president for assent. But if both Houses disagree on the
bill, then bill is presented before joint sitting of parliament and once passed from there with
majority then it is sent to president for assent.

4- BRANCHES OF GOVERMENT

4.1 BICAMERAL LEGISLATURE

Article 50 of the constitution of 1973 provides that there shall be a Majlis-e shoora of Pakistan
consisting of the president and 2 houses to be known respectively as National Assembly (Lower
House) and the senate (Upper House.
In U.K there is also BICAMERAL legislature consists of 2 houses .First one is House of
Commons (lower and most powerful and more influential than HOL) .2nd one is HOL
(hereditary house).
4.1.1 NATIONAL ASSEMBLY (A-51) & THE HOUSE OF COMMONS

• LOWER HOUSES AND ELECTED: Both National assembly and HOC are lower
Houses and are elected directly by the public. National assembly is elected on population
basis.
 • TENURE. Both National assembly and HOC are elected for 5 years but can be dissolved
earlier on the advice of P.M by the president or King as the case may be.
• MEMBERS: there are total 336 members in N. A and members called MNAs. However,
there are total 650 members in HOC and these members are called MPs (members of
parliament.
• POWERFUL CHAMBER: National Assembly in Pakistan and House of Commons in
U.K both are more powerful than their respective upper Houses.

But House of commons is more powerful than National assembly in Pakistan because new
British parliament simply means new HOC and laws passed by it cannot be challenged or strike
down by judiciary in judicial review but laws passed by National Assembly in Pakistan can be
challenged and strike down by judiciary if found ultra – vires of the constitution.

• Speaker and deputy speakers: Speaker presides over the meetings of both HOC in U.K
and National Assembly in Pakistan. There are 3 deputy speakers in the HOC elected by
MPs to assist the speaker.

• Quorum: Minimum Quorum required for running the business of National Assembly is
one -fourth of the total members of the House. And minimum quorum requirement in
HOC is 40 MPs out of 650.
• Representation: Both National assembly and HOC represent the interests of the nation
as whole and represent the democracy.
4.1.2 SENATE (A-59) & HOUSE OF LORDS

• UPPER HOUSE: Senate is the upper House of parliament in Pakistan and HOL is
the world’s oldest and 2nd largest upper chamber in U.K.

• COMPOSITION: senate is composed of total 96 members. In contrast to that

House of Lords consists of lords spiritual and lord’s temporal (Hereditary and life
peers). It has 784 sitting members’ but this number is not fixed.

• ELECTED AND NON-ELECTED / HEREDITARY: Members of Senate (upper

House) are elected by the provincial assemblies on the basis of proportional
representation.
HOL members (life peers) are appointed by the monarch on the advice of the Prime
Minister and the hereditary peers are the descendants of individuals who were
granted peerages by the crown.

• MEMBERS: Members of senate are called senators and members of HOL are called
peers.
• INTRODUCED: Senate introduced first time in 1973 constitution...House of lords
is older than House of commons’ and is one of the oldest chamber in the world its
origin lies in the early 11th century and the emergence of bicameralism in 13th
century.
• Powers: Senate has almost equal power compared to the National Assembly. Senate
can initiate legislation like N.A except money bills. Senate can review and reject
bills that originate in NA and can propose amendments to legislation passed by N.A
and also can delay the bills for up-to 90 days. No bill can be passed without approval
of senate

In contrast to that House of Lords does not enjoy extensive legislative powers like
HOC after passage of parliament acts 1911 and 1949.All-important bills originate in
the HOC such as money bills. And HOL have no power to modify or reject it. HOL
is only a delaying chamber.

HOL can delay ordinary bills passed by HOC only for 1 year but cannot
permanently block them. Bill can become a law even without HOL approval.

We can say that senate in Pakistan is stronger house than HOL in U.K but both
houses are less powerful as compared to their respective lower Houses

• Term: Members have a six-year term, with half the members are elected every 3
years. Life peers hold seats in the House of Lords for their life, while hereditary
peers hold their seats until they die or disclaim their peerage. Hereditary peers can be
removed by the House of Lords act 1999.

• Political influence: The house of lords is generally considered less politically

influential than the House of Commons but the senate of Pakistan is considered more
politically influential, particularly in relation to matters affecting provinces.

• Public perception: House of lord is for being undemocratic and unrepresentative

due to the presence of hereditary peers, senate of Pakistan is also subject to criticism
but it is generally seen as a more legitimate and more representative body.

• Representation: In Senate there is parity of representation. Senate represents

interests of the provinces while HOL is supposed to represent the interest of nation as
a whole.
• Permanent Houses: Both senate and HOL are permanent Houses.

• Lord speaker and deputy speakers: Lord Speaker is the presiding officer of the
House of Lords elected by the HOL. Earlier Lord chancellor was pressing officer of
HOL. In the House of Lords, a panel of 20 to 25 deputy speakers assists the lord
speaker .in presiding over debates when lord speaker is absent.
 • Chairman and deputy chairman: There is a chairman and deputy chairman in
senate of Pakistan. Chairman presides over the meetings of senate. In case of absence
of any of them senate elects another member as chairman or deputy chairman.
4.2 EXECUTIVE
The executive branch of both U.K and Pakistan consists of cabinet d is led by the Prime Minister
/chief executive. Executive branch of both states is part of legislature.

U.K CABINET:
Formation: The Cabinet is composed of senior government ministers chosen by the
Prime Minister who is the head of the cabinet. Members are called ministers.
Collective Responsibility: Cabinet members are collectively responsible for government
policies and decisions.

Ministerial Code: The Cabinet operates under the principles outlined in the Ministerial
Code, emphasizing collective responsibility and confidentiality.
No Fixed Number: The size of the Cabinet is not fixed, and it can vary depending on the
preferences of the Prime Minister.
Cabinet Meetings: Regular Cabinet meetings are held to discuss and decide on major
policy issues.
Accountable: Ministers are accountable for their actions to the British parliament.
U.K PRIME MINISTER:
Selection: The Prime Minister is the leader of the political party that wins the most seats
in the House of Commons during a general election.

Royal Assent: The Prime Minister is formally appointed by the monarch but must have
the confidence of the House of Commons.
Head of Government: The Prime Minister is the head of the government and is
responsible for running the country and making policy decisions.
No Term Limits: There are no fixed term limits for the Prime Minister, as long as they
maintain the support of their party and the majority in the House of Commons.
PAKISTAN CABINET:
Formation: The Cabinet is formed by the Prime Minister who is its head, and its
members are appointed by the President on the advice of the Prime Minister. Members are called
ministers

Collective Responsibility: Similar to the UK, Cabinet members are collectively

responsible for government policies and decisions.
 Cabinet Division: The Cabinet Division facilitates coordination among various
ministries and divisions.
Fixed Number: Total strength of the cabinet shall not exceed 11 percent of the total
membership of parliament.
Accountable: cabinet ministers are answerable for their actions to the parliament.
PAKISTAN PRIME MINISTER:
Selection: The Prime Minister is the leader of the majority party or coalition in the
National Assembly and is elected from it.

Appointment: The President formally appoints the Prime Minister, who must command
the confidence of the National Assembly.
Head of Government: The Prime Minister is the chief executive and head of
government, responsible for policy-making and administration.
Term Limits: There is no any restriction on the number of terms for the office of the
Prime Minister.
4.3 JUDICIARY
The judicial systems in Pakistan and the UK differ in various aspects. Here are some key
differences between the judiciary systems of Pakistan and the UK:
Legal System: Pakistan follows a civil law system influenced by Islamic law (Sharia) in
certain areas, while the UK's judiciary operates under a common law system based on precedents
and case law.
Structure: Pakistan has a Supreme Court at the top, followed by High Courts and
subordinate courts. The UK has a Supreme Court as well, along with lower courts like Crown
Courts, High Courts, and Magistrates' Courts.
Constitutional Framework: Pakistan's judiciary is governed by the Constitution of
Pakistan, which outlines the structure and powers of the courts. In the UK, the judiciary's powers
are derived from various sources, including statutes, common law, and constitutional
conventions.
Legal Procedure: The legal procedures and court processes in both countries differ due
to their distinct legal systems. For instance, Pakistan may have specific procedures influenced by
Islamic law in certain cases, while the UK emphasizes adherence to precedents and case law.
Independence: The UK has a more established tradition of an independent judiciary than
in Pakistan.
Appointments and Tenure: In Pakistan, judges are appointed by the President after
consulting with the Chief Justice. In the UK, judges are appointed by the Crown on the advice of
a selection commission, and they often have secure tenure until retirement.
 Role of Islamic Law: Pakistan's judiciary, in certain areas, deals with cases involving
Islamic law principles. The UK judiciary does not incorporate Islamic law into its legal
framework.

Specialized Courts: Pakistan has specialized courts, such as anti-terrorism courts, family
courts, and others catering to specific legal areas. The UK also has specialized courts but often
operates with a more integrated structure, where various legal matters are addressed in general
courts.
Precedent and Case Law: The UK places significant emphasis on legal precedent and
case law, where decisions made in higher courts set legal precedents for lower courts to follow.
In Pakistan, while precedents do hold weight, they might not have the same binding effect as in
the UK's common law system.

COMPARISON BETWEEN CROWN (QUEEN /KING) / AND PRESIDENT.

The UK Crown and the Pakistan President are fundamentally different in several key aspects:
1. Head of state
UK Queen: Constitutional monarch, serving as Head of State but with limited political power.
Acts as a symbol of national unity and tradition.

Pakistani President: Head of State holding significant executive power. Responsible for forming
the government, appointing ministers, and commanding the armed forces
2. Selection
UK Crown: The British monarch inherits the position through hereditary succession. The eldest
child of the reigning monarch automatically becomes the next sovereign.

Pakistan President: The Pakistani president is an indirectly elected official chosen by an electoral
college composed of members of the Parliament and the four provincial assemblies.
3. Role and powers
UK Crown: The British monarch has a primarily ceremonial role and limited executive power.
Most powers are exercised by the Prime Minister and the government. The monarch serves as a
symbol of national unity and performs official duties such as dissolving Parliament, appointing
the Prime Minister, and granting Royal Assent to bills.
Pakistan President: The Pakistani president has both ceremonial and some executive powers. He
is the commander-in-chief of the armed forces and hold the power to appoint key officials,
including the Prime Minister and judges and dissolves N.A on the advice of P.M. The president
also has the authority to grant pardons and reprieves and also promulgate ordinances and gives
assent to bills passed by parliament.
4.Accountability
UK Crown: The British monarch is immune from prosecution and cannot be held accountable for
their actions in their official capacity. They are considered to be "above the law."
Pakistan President: The Pakistani president can be impeached by Parliament for treason, bribery,
or other serious offenses.
5.Tenure
The UK Crown holds the position for life, whereas the Pakistani President serves a five-year
term with the possibility of one re-election.
6. Salary

The Queen receives a sovereign grant funded by the Treasury, while the President of Pakistan
receives a salary and benefits determined by the government.
7. Political influence
The UK Crown has limited political influence and is expected to remain neutral in political
matters. The Pakistani President, however, can exercise significant political influence,
particularly in their role as commander-in-chief and through the appointment of key officials.
8. Historical context
The UK Crown is a centuries-old institution deeply rooted in British history and tradition. The
Pakistani presidency is a more recent position established after 1st constitution.
9.Religion

Pakistani president must be a Muslim while Queen must be of protestant faith and she is a
supreme Governor of church of England.

RULE OF LAW

A. V Diceys gave a concept rule of law. Rule of law is main principle of U.K constitution. A
principle that all people and institutions are subject to and accountable under the law including
government.
Both U. K and Pakistan have a commitment to the rule of law enshrined in their respective
constitution Parliamentary sovereignty in U.K can limit the ability of judiciary to uphold rule of
law. In Pakistan military influence and limited access to justice undermine the rule. Of law and
human rights . Both states are facing challenges in implementation of rule of law.

FUNDAMENTAL RIGHTS

Both states protect fundamental human rights of their citizens. constitution. of 1973 article 8to28
deals with Fundamental rights.